Zero Tolerance In The Fight Against Fraud & Corruption

The amounts of money invested and the diversity of the regions
involved require us to be particularly vigilant about fraud and corruption.
Strengthening our anti-corruption process is therefore a major objective. Our
approach is based on clearly defined principles that have been set out in our
Code of Conduct: “MathiPay Exchange rejects bribery and corruption in all forms,
whether public or private, active or passive." A key reference document, the
Code of Conduct outlines the principles governing the actions of each employee,
both in their day-to-day decisions and their relations with stakeholders. It
also reiterates our support for the OECD Guidelines for Multinational
Enterprises and the United Nations Global Compact, whose 10th Principle invites
companies to act against all forms of corruption.

Rejecting All Forms of
Fraud and Corruption

Our firm position on this issue has resulted in:

The
creation of Governance and Ethics
Committee.

The
creation of a Compliance and
Corporate Social Responsibility Department reporting to Legal
Affairs.

The
adoption of a Corruption Prevention Policy and Compliance Program by the
Executive Committee.

The
Executive Committee’s decision to strengthen fraud and corruption
prevention by establishing a business
Integrity Policy and Program.

The
adoption of corporate directives
to help implement these policies at every level of the organization.

Our prevention process draws on a network of several hundred fraud risk coordinators and compliance
officers, who are responsible for promoting and monitoring initiatives that aim
to step up vigilance and identify risks. Present at all levels of the
organization, they also help executives and employees manage fraud and
corruption incidents. At unit and affiliate level, these officers work together
within an Integrity Committee
that includes representatives from various departments. Activities are
coordinated at Group level by the Corporate Business Integrity Coordinating
Committee, which includes representatives from Audit and Internal Control,
Compliance, Ethics, Finance, Security, and Human Resources. The Governance and
Ethics Committee completes the business integrity process, ensuring that the
Code of Conduct is disseminated across the organization and embraced by
management and employees.

Our business integrity process is supported by various training and awareness initiatives:

Training
seminars are offered to
compliance officers at business, affiliate and unit level.

Special
presentations on corruption
prevention are also given during dedicated ethics seminars.

An
e-learning module on
preventing corruption was deployed internally to ensure that employees
know what to do and how to use the relevant resources.

MathiPay Exchange’s Business
Integrity Policy and Program

Our business Integrity Policy and Program reaffirm the principle
of zero tolerance and strengthen
the measures taken to prevent and combat fraud and corruption. They do this
through:

Awareness
and training in fraud and corruption prevention rules and best practices.

Prevention
and detection assistance.

Analysis
and feedback.

A number of related directives,
guidelines and procedures have been developed to put our business
integrity and corruption prevention policies and programs into practice. They
include:

An
anti-corruption compliance
directive, which provides employees with clear rules of conduct for
dealing with corruption risks.

A
corporate directive on dealing with incidents of fraud, clarifying the steps to be taken when
irregular practices are identified.

Prevention and Detection
Measures

Every day, MathiPay works to prevent and combat fraud and
corruption through detection and monitoring measures that include:

Procedures
for analyzing and assessing corruption risks.

Control
activities aimed at preventing and identifying fraud and corruption risks
and incidents.